Court of Appeals for the Fifth Circuit August 16, 1982, 81-4425 (H. C. Franklin and Marjorie Franklin v. Commissioner of Internal Revenue)

ALVIN B. RUBIN, Circuit Judge:

We here consider the deductibility of interest paid by a cash basis taxpayer with money borrowed to fulfill his interest obligations on loans made in participation by a group of banks. The taxpayer borrowed from the lead bank to pay interest due both that bank and the other banks that had participated in loans to him.